Code of Ethics

SURREY BANCORP CODE OF ETHICS FOR SENIOR OFFICERS

I. Statement of Purpose

Surrey Bancorp (“Company”) maintains high standards of conduct in keeping with our statutory and moral responsibilities to our shareholders and the investing public. Our reputation for honesty, integrity and confidentiality is vital to our success. This code of conduct (“Code”) applies to the offices of Chief Executive Officer, Chief Financial Officer, chief credit officer, principal branchoperations/administration officer, principal accounting officer and the controller. Its purpose is to insure that all senior officers of the Company understand and observe the basic principles that govern our personal and corporate conduct in our community.

II. Compliance with Legal Requirements

The guiding policy of the Company is that all officers abide by the letter and the spirit of all applicable statutes, regulations, rules, orders, and policy statements or other similar provisions that apply to the operation of the Company. The Company will not tolerate any violation or intent to violate these legal requirements.

III. Fair and Complete Public Disclosure

As an officer of a publicly traded company, all senior officers shall ensure full, fair, accurate, timely and understandable disclosure in all public reports and documents that the Company files with, or submits to, the Securities and Exchange Commission and in all communications that the Company gives to the public.

IV. Responsible Conduct

All senior officers of the Company are required to act in a responsible and respectful manner consistent with the behavior of a person of integrity and should proactively promote ethical behavior by all our employees. A senior officer shall remain free of any influences that may interfere, or give the appearance of interfering, with the independent and objective exercise of his or her judgment on behalf of the Company.

V. Confidential Information

Safeguarding confidential information is essential to the normal conduct of the business of the Company.

A. Customer Information
Customer information is privileged and shall be released only to those employees who have a need to know such information.

B. Employee Information
Information concerning present or former employees is considered confidential and shall not be released to anyone except under procedures approved by the Human Resources Department.

C. Corporate Information
Material financial information and material information relating to the business activities of the Company and its affiliated companies shall not be disclosed to any person, unless the information has been made available to the public in accordance with law. Likewise, material non-public information is not to be used for any personal financial gain or for the financial gain of a friend or relative. See also the Insider Trading Policy of the Company.

VI. Conflicts of Interest

Officers should strive at all times to avoid not only actual conflicts of interest but also the appearance thereof. Senior officers shall not (a) take for themselves personally opportunities that are discovered through the use of corporate property, information or position; (b) use corporate property, information or position for personal gain; or (c) compete with the Company. It is incumbent upon each senior officer to exercise his or her own best judgment as to whether or not a conflict exists and whether it would justify remedial action. In a doubtful situation, the matter should be first fully disclosed and discussed with the chief executive officer or the Chair of the Audit Committee.

VII. Reporting of Violations

Senior officers should promote ethical behavior. Senior officers should encourage employees to talk to supervisors or other designated personnel when in doubt about the best course of action in a particular situation. Senior officers should report, and encourage employees to report, violations of this Code to designated personnel. The Company will not tolerate retaliation for reports made in good faith and senior officers should ensure that employees are aware of that policy. Any material violation of the Code should be reported to the Chair of the Audit Committee.

VIII. Enforcement

Violations of the Code are subject to disciplinary action, up to and including termination of employment. Discipline for violations of the Code will be administered in accordance with the Personnel Policy of the Company.

If appropriate remedial measures or sanctions with respect to the violations are not taken within a reasonable period of time, officers should report the violation to the Chairman of the Board, or, if remedial measures or sanctions are not then taken, to the full Board.

IX. Administration of the Code

Administration of the Code shall be vested in the Audit Committee. A quorum shall consist of at least three members of the Audit Committee.

Questions concerning interpretation of the Code should be submitted first to the Chair of the Audit Committee. The Audit Committee shall have complete discretion and authority in the interpretation of the Code. The Audit Committee may recommend revisions to the Code as the need arises. The Audit Committee has the right to make exceptions to any provision of the Code, the waiver of which would be in the best interests of the Company and its officers, employees, shareholders, and customers.

Any change in the Code that applies to the CEO, chief financial officer, principal accounting officer or controller, or the granting of a waiver of any provision of the Code to any such officer, shall be publicly reported within two business days after such change or waiver. Public reporting shall mean disclosure through the filing of a Form 8K with the Securities and Exchange Commission or posting of the change or waiver on the Company’s website.

Surrey Bank & Trust

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